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Jiao v. Blumenthal

United States District Court, W.D. Washington, Seattle

November 17, 2017

JIE JIAO, Plaintiff,
v.
CONNIE BLUMENTHAL, et al., Defendants.

          STIPULATED PROTECTIVE ORDER

          JOHN C. COUGHENOUR, UNITED STATES DISTRICT JUDGE.

         Pursuant to the parties' stipulated motion for a protective order (Dkt. No. 15), the Court ORDERS as follows:

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this agreement is consistent with Local Civil Rule 26(c). It does not confer blanket protection on all disclosures or responses to discovery, the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal.

         THE HONORABLE JOHN C. COUGHENOUR

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged:

- Plaintiff's confidential material includes all bank records, employment records, and all personal financial information of plaintiff or any one or more of her immediate family members.
- Defendant Blumenthal's confidential material includes all bank records; personal financial data; personal and private information of third parties; business records and private transactions of other customers; and confidential documents of Realogics Brokerage, LLC.
- Defendant Realogics Brokerage, LLC d/b/a Realogics Sotheby's International Realty's confidential material includes trade secrets, commercial operations, proprietary business records, confidential financial records, tax returns, all transactions involving the personal and private information of third parties and customers, employment records, bank records, identification of customers, financial documents of third parties and customers; communications with other customers in unrelated transactions, including text message and email correspondence.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material.

         However, the protections conferred by this agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 Basic Principles.

         A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the person authorized under this agreement.

         4.2 Disclosure of “CONFIDENTIAL” Information or Items.

         Unless otherwise ordered by the Court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in-house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material ...

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